SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 6010

August 22, 2005

Donald R. Head
President and Chief Executive Officer
Capital Title Group, Inc.
14648 N. Scottsdale Rd., Ste. 125
Scottsdale, AZ   85254

Re:	Capital Title Group, Inc.
	Form 10-K for Fiscal Year Ended December 31, 2004
	Filed March 17, 2005
	File No. 000-21417

Dear Mr. Head:

      We have limited our review of your filing to those issues we
have addressed in our comments.  Where indicated, we think you
should
revise your document in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we ask
you
to provide us with information so we may better understand your
disclosure.  After reviewing this information, we may raise
additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and ..., page 21

Contractual Obligations table, page 30
1. Please include the expected settlement of your reserve for
title
insurance and escrow losses in the contractual obligation table.
In
this regard, please note that it would appear that these represent
future legal obligations of yours.  Due to the apparently
significant
nature of these liabilities to your business, we believe the
inclusion of these liabilities in the contractual obligation table
will provide investors increased disclosure of your liquidity.
The
purpose of Item 303(a)(5) and Financial Reporting Release 67
appears
to be to obtain enhanced disclosure concerning your contractual
payment obligations and the exclusion of ordinary course items
would
appear to be inconsistent with that purpose.

Item 8.  Financial Statements, page 32

Notes to Consolidated Financial Statements, page 37

1.  Organization and Summary of Significant Accounting Policies,
page
37

Significant Accounting Policies, page 38

Revenue Recognition, page 39
2. Please clarify for us what the underwriting fees represent and
why
netting them against title service revenues complies with GAAP.
In
so doing, please tell us the specific literature supporting this
presentation.
3. Please tell us the basis used to recognize flood zone
determination service revenue over the period you are
contractually
obligated to provide the service and how that basis is consistent
with your pattern of performance during that period.

8.  Summary of Reserve for Title Insurance and Escrow Losses, page
50
4. Please tell us where you have provided all of the disclosures
required by paragraph 11 of SOP 94-5 or make any of those
disclosures
that have not already been made.

*    *    *    *

   As appropriate, please amend your filing and respond to these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing include all information required under the Securities
Exchange
Act of 1934 and that they have provided all information investors
require for an informed investment decision.  Since the company
and
its management are in possession of all facts relating to a
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

	In connection with responding to our comments, please
provide,
in your letter, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Ibolya Ignat, Staff Accountant at (202) 551-
3656, or Oscar M. Young, Senior Accountant at (202) 551-3622 if
you
have questions regarding the comments.  In this regard, do not
hesitate to contact me, at (202) 551-3679.

								Sincerely,

								for Jim B. Rosenberg
								Senior Assistant Chief
      Accountant
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Donald R. Head
Capital Title Group, Inc.
August 22, 2005
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